SEC Division of Investment Management staff letter: Townsend and Associates, Inc.

The SEC staff advises Townsend and Associates, Inc. that it may rely on the broker-dealer exclusion from investment adviser registration under the Investment Advisers Act of 1940 if its advisory services are solely incidental to its brokerage business and it receives no special compensation. The staff clarifies that receiving cash referral fees from investment advisers does not constitute special compensation, though Rule 206(4)-3 obligations apply. The letter further instructs the firm to clarify its stationery to ensure the term "Registered Investment Advisor" accurately reflects the status of its affiliated broker-dealer, Consolidated Investment Services.

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DIVISION OF

INVESTMENT MANAGEMENT
September 21, 1994

Mr. Jeff Townsend

Townsend and Associates, Inc.

1120 Lincoln Street, suite 708

Denver, CO 80203

Dear Mr. Townsend:

In your letter dated August 10, 1994, you state that you are

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